[Federal Register Volume 74, Number 25 (Monday, February 9, 2009)]
[Notices]
[Pages 6423-6430]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E9-2615]
[[Page 6423]]
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NUCLEAR REGULATORY COMMISSION
[Docket Nos. 50-277 and 50-278; NRC-2009-0033]
Exelon Generation Company, LLC and PSEG Nuclear, LLC Peach Bottom
Atomic Power Station Unit Nos. 2 and 3; Exemption
1.0 Background
The Exelon Generation Company (Exelon, the licensee in addition to
PSEG Nuclear, LLC) is the holder of Facility Operating License Nos.
DPR-44 and DPR-56 which authorize operation of the Peach Bottom Atomic
Power Station (PBAPS) Units 2 and 3. The licenses provide, among other
things, that the facility is subject to all rules, regulations, and
orders of the U.S. Nuclear Regulatory Commission (NRC, the Commission)
now or hereafter in effect.
The facility consists of two boiling-water reactors located in York
and Lancaster Counties, Pennsylvania.
2.0 Request/Action
Title 10 of the Code of Federal Regulations (10 CFR), Part 50,
Section 50.48, requires that nuclear power plants that were licensed
before January 1, 1979, must satisfy the requirements of 10 CFR part
50, Appendix R, Section III.G, ``Fire protection of safe shutdown
capability.'' PBAPS Units 2 and 3 were licensed to operate prior to
January 1, 1979. As such, the licensee's Fire Protection Program (FPP)
must satisfy the established fire protection features of 10 CFR part
50, Appendix R, Section III.G. NRC Regulatory Information Summary (RIS)
2006-10, ``Regulatory Expectations with Appendix R Paragraph III.G.2,
Operator Manual Actions,'' noted that NRC inspections identified that
some licensees had relied upon operator manual actions, instead of the
options specified in 10 CFR part 50, Appendix R, Section III.G.2 as a
permanent solution to resolve issues related to Thermo-Lag 330-1 fire
barriers.
In a letter dated October 5, 2007 (Agencywide Documents Access and
Management System (ADAMS) Accession Number ML072820129), the licensee
identified 25 operator manual actions that were previously included in
correspondence with the NRC and found acceptable in a fire protection-
related Safety Evaluation (SE) dated September 16, 1993 (ADAMS
Accession Number ML081690220). However, RIS 2006-10 identifies that an
exemption under 10 CFR 50.12 is necessary for use of the manual actions
in lieu of the requirements of 10 CFR part 50, Appendix R, Section
III.G.2 even if the NRC previously issued an SE that found the manual
actions acceptable. This exemption provides the formal vehicle for NRC
approval for the use of the specified operator manual actions instead
of the options specified in 10 CFR part 50, Appendix R, Section III.G.2
for PBAPS Units 2 and 3.
In summary, by letter dated October 5, 2007, and supplemental
letters dated May 1, 2008, and December 11, 2008 (ADAMS Accession
Numbers ML081220873 and ML083470170) responding to the NRC staff's
request for additional information, Exelon submitted a request for
exemption from 10 CFR Part 50, Appendix R, Section III.G, ``Fire
Protection of Safe Shutdown Capability,'' for the use of 25 operator
manual actions as described in Table 1 in lieu of the requirements
specified in Section III.G.2.
3.0 Discussion
Pursuant to 10 CFR 50.12, the Commission may, upon application by
any interested person or upon its own initiative, grant exemptions from
the requirements of 10 CFR Part 50 when: (1) the exemptions are
authorized by law, will not present an undue risk to public health or
safety, and are consistent with the common defense and security; and
(2) when special circumstances are present. One of these special
circumstances, described in 10 CFR 50.12(a)(2)(ii), is that the
application of the regulation in the particular circumstances would not
serve the underlying purpose of the rule, or is not necessary to
achieve the underlying purpose of the rule.
The underlying purpose of 10 CFR part 50, Appendix R, Section
III.G.2 is to ensure that one of the redundant trains necessary to
achieve and maintain hot shutdown conditions remains free of fire
damage in the event of a fire. Section III.G.2 provides the following
means to ensure that a redundant train of safe shutdown cables and
equipment is free of fire damage, where redundant trains are located in
the same fire area outside of primary containment:
a. Separation of cables and equipment by a fire barrier having a 3-
hour rating;
b. Separation of cables and equipment by a horizontal distance of
more than 20 feet with no intervening combustibles or fire hazards and
with fire detectors and an automatic fire suppression system installed
in the fire area; or
c. Enclosure of cables and equipment of one redundant train in a
fire barrier having a 1-hour rating and with fire detectors and an
automatic fire suppression system installed in the fire area.
Exelon indicated that the operator manual actions listed in their
October 5, 2007, exemption request are those that were previously
included in correspondence with the NRC and were found acceptable in a
Fire Protection SE dated September 16, 1993 (ADAMS Accession Number
ML081690220). The introductory letter to this SE states, in part,
The NRC staff has completed a review of the ``Fire Protection
Program'' document through Revision 4 as well as certain other
documents related to the implementation of Appendix R requirements.
The enclosed safety evaluation (SE) concludes that the safe shutdown
capability at Peach Bottom, as described in the PBAPS Fire
Protection Program, with approved exemptions, satisfies the
requirements of Section III.G and III.L of Appendix R to 10 CFR Part
50.
Section 2.6 titled ``Manual Operations,'' of the September 16,
1993, SE states, in part,
Each of the four shutdown methods identified by the licensee in
the FPP, (Methods A, B, C, and D), require that manual actions be
performed outside of the control room to achieve shutdown following
fires in certain fire areas. Table A-4 of the FPP describes the
manual operations that may be required and the fire areas that may
require manual actions. [* * *] Based on the review conducted as
part of Inspection Report 87-30 and the closure of Open Item 87-30-
02, the NRC staff finds the manual operations described in the FPP
acceptable.
A cross reference between Table A-4 of the PBAPS Units 2 and 3 FPP,
Revision 3, titled ``Operations that may be Required to be Performed
Outside the Control Room,'' and the operator manual actions identified
in the October 5, 2007, Request for Exemption was provided in table
format in the May 1, 2008, Response to Request for Additional
Information. This information is provided in Table 1 of this exemption
titled, ``Cross-Reference Between Peach Bottom Fire Protection Program,
Revision 3, Table A-4 and Operator Manual Actions.'' There are a total
of 25 operator manual actions listed in the exemption that occur in 11
different fire areas.
Exelon indicated in the May 1, 2008, Response to Request for
Additional Information that in several cases, certain individual
operator manual actions that were approved in the SE are divided into
separate tasks for clarity as part of the exemption request. Also, in
several cases, additional tasks are specified. The additional tasks are
listed when the tasks are performed in a different room from the main
action. Exelon states that this was done to clearly identify the
[[Page 6424]]
areas in which the manual actions are performed and are not new actions
that did not previously exist.
In the December 11, 2008, Response to Request for Additional
Information, the licensee outlined the approach that was taken to
evaluate and assess the effectiveness of the operator manual actions
included in the request. The cross-reference information provided in
Table 1 provides an explanation for where each operator manual action
is located and the role of the actions in achieving safe shutdown. The
response also contains a discussion and justification for why the
operator manual actions are appropriate for maintaining consistency
with the intent of Section III.G.2 of Appendix R.
The NRC staff reviewed the licensee's evaluation in support of the
subject exemption request for the use of operator manual actions in
lieu of the requirements specified in Section III.G.2 of Appendix R,
and concluded that given the existing fire protection features in the
affected fire zones, Exelon continues to meet the underlying purpose of
10 CFR Part 50, Appendix R, Section III.G.2 for the PBAPS Units 2 and 3
fire areas described in Table 1. The following technical evaluation
provides the basis for this conclusion.
3.1 Fire Prevention
Fire areas 2, 6S, 13N, 13S, 26, 38, 54 and 57 all have limited or
low combustible fuel loading (equivalent fire severity of less than 45
minutes) and fire areas 4, 50 and 58 have low to moderate combustible
fuel loading (equivalent fire severity of less than 105 minutes). Fire
area 50 also contains some individual rooms, such as the lube oil
rooms, that include high combustible fuel loading (equivalent fire
severity of greater than 105 minutes). Areas with moderate or greater
fuel loading have adequate detection and suppression systems
appropriate for the hazard as described below.
The primary fixed ignition sources in the areas are limited to
cables and electrical equipment. It is noted that in all areas where a
postulated fire included an electrical cable fire, all exposed cables
have fire retardant insulation material and that the use of wood is
restricted to fire retardant wood (except for large cribbing).
The NRC staff finds that for all of the areas related to this
exemption, the level of fire protection combined with the limited fuel
load and minimal ignition sources in the fire areas associated with
this exemption results in a low likelihood of a fire occurring and
spreading to adjacent fire areas or equipment.
3.2 Detection, Control and Suppression
The NRC staff evaluated the fire detection, control and suppression
systems associated with the areas related to this exemption. All fire
areas included in this exemption have smoke detection systems
installed. Fire areas 4, 13S, 26, 38, 54, 57 and 58 have full-area
smoke detection coverage. Fire area 2 is provided with smoke or heat
detection in most rooms with the exception of some of the radwaste pump
and tank rooms that are locked high radiation areas. Fire areas 6S and
13N have smoke detection coverage on each elevation except the
refueling floor, where there are no cables associated with safe
shutdown. Fire area 50 has smoke and/or heat detection systems
installed in certain individual rooms within the turbine building to
address specific fire hazards.
Fire areas 2, 4, 38, 57 and 58 also have full-area automatic fire
suppression systems installed to mitigate any specific or elevated fire
hazards in those areas. An example of a specific or elevated fire
hazard would be the cable insulation, lube oil, charcoal filters or
trash/paper noted as being postulated fires in fire area 2. These fire
hazards are mitigated by the installation of carbon dioxide systems in
each High Pressure Coolant lnjection pump room, pre-action sprinklers
over the motor generator set lube oil pumps, wet pipe sprinklers in the
radwaste trash area and water spray for the charcoal filters that are
part of the standby gas treatment system. Fire Area 57 is equipped with
a pre-action sprinkler system to protect the corridor that passes
between the 4kV bus rooms and the radwaste building.
Fire area 50 has fire detection and local automatic fire
suppression systems installed in specific areas to suppress fires that
may occur at the specific hazard source or to protect access through
the area. For example, the licensee noted in the December 11, 2008,
Response to Request for Additional Information, that some high
combustible fuel load areas, such as the lube oil, moisture separator,
feed pump rooms, turbine bearings and the common hatch area, are
located in fire area 50 and that these spaces were equipped with wet-
pipe sprinkler systems. The licensee also noted that the hydrogen seal
skid on each unit is equipped with an automatic deluge system and that
a pre-action sprinkler system is installed over the 13kV switchgear
cabinets in fire area 50.
The NRC staff finds that for the areas described in the request for
exemption, the fire detection, control and suppression systems are
adequate to mitigate any specific or elevated fire hazards in those
areas.
3.3 Preservation of Safe Shutdown Capability
The NRC staff has evaluated the feasibility review provided by the
licensee in the December 11, 2008, Response to Request for Additional
Information. The feasibility review documents that procedures are in
place, in the form of Transient Response Implementing Plan procedures,
to ensure that clear and accessible instructions on how to perform the
manual actions are available to the operators. Several potential
environmental concerns are also evaluated, such as radiation levels,
temperature/humidity conditions and the ventilation configuration and
fire effects that the operators may encounter during certain emergency
scenarios. The licensee's feasibility review concluded that the
operator manual actions were feasible because the operators performing
the manual actions would not be exposed to adverse or untenable
conditions during any particular operator manual action procedure or
during the time to perform the procedure.
The NRC staff reviewed the required operator manual action
completion time limits versus the time before the action becomes
critical to safely shutting down the unit as presented in the
feasibility analyses. In one case the action must be completed within
30 minutes. This action is identified in Table 1 as 30S546 and requires
an operator to travel from the control room to the cable spreading room
and perform the action of operating a key switch. The combined time to
complete the travel and specified action requires a total of 5 minutes.
Given the low complexity of this action the NRC staff finds that this
action is feasible. In addition, the fire areas described in this
exemption are separated from adjacent fire areas by fire-rated barriers
or water curtains to provide a level of compartmentalization between
the fire areas and/or buildings. This compartmentalization helps to
ensure that fires will not spread to adjacent fire areas and that any
fire damage will be limited to the fire area of origin. The NRC staff
finds that there is a sufficient amount of time available to complete
the proposed operator manual actions specified in Table 1 of this
exemption.
3.4 Evaluation
As stated in 10 CFR Part 50, Appendix R, Section II:
[[Page 6425]]
The fire protection program shall extend the concept of defense-
in-depth to fire protection with the following objectives:
1. To prevent fires from starting,
2. To detect rapidly, control, and extinguish promptly those
fires that do occur, and
3. To provide protection for structures, systems, and components
important to safety so that a fire that is not promptly extinguished
by the fire suppression activities will not prevent the safe
shutdown of the plant.
The NRC staff has evaluated the elements of defense-in-depth used
for fire protection at PBAPS, applicable to the fire zones under
review. Based upon consideration of the limited fire ignition sources
and fire hazards in the affected areas, and the existing fire
protection measures at PBAPS, the NRC staff concludes that objective
one of defense-in-depth is adequately met.
Based on the evaluation of fire detection and suppression systems
provided in the affected fire zones, the NRC staff determined that any
postulated fire is expected to be promptly detected by the available
automatic fire detection systems in the associated fire areas. The
available fire detection and suppression equipment in these fire areas
ensure that a postulated fire will not be left unchallenged. In
addition, all fire areas are separated from adjacent fire areas by
fire-rated barriers or water curtains to provide a level of
compartmentalization between the fire areas and/or buildings. This
compartmentalization helps to ensure that fires will not spread to
adjacent fire areas and that any fire damage will be limited to the
fire area of origin. In addition, when fires are contained in the fire
area of origin, the licensee has demonstrated that the manual actions
are feasible. Therefore, the NRC staff concludes that objectives 2 and
3 of defense-in-depth are adequately met.
Therefore, the NRC staff concludes that the requested exemption to
use operator manual actions in lieu of the requirements of 10 CFR Part
50, Appendix R, Section III.G.2 is consistent with the defense-in-depth
methodology necessary at nuclear power plants and will not impact PBAPS
post-fire safe-shutdown capability.
3.5 Authorized by Law
This exemption would allow PBAPS the use of operator manual actions
in lieu of meeting the requirements specified in 10 CFR Part 50,
Appendix R, Section III.G.2. As stated above, 10 CFR 50.12 allows the
NRC to grant exemptions from the requirements of 10 CFR Part 50. The
NRC staff has determined that granting of the licensee's proposed
exemption will not result in a violation of the Atomic Energy Act of
1954, as amended, or the Commission's regulations because special
circumstances exist that warrant the use of the operator manual actions
to achieve safe shutdown. Therefore, the exemption is authorized by
law.
3.6 No Undue Risk to Public Health and Safety
The underlying purpose of 10 CFR part 50, Appendix R, Section
III.G.2 is to ensure that one of the redundant trains necessary to
achieve and maintain hot shutdown conditions remains free of fire
damage in the event of a fire. Based on the existing fire barriers,
fire detectors, automatic and manual fire suppression equipment, fire
protection requirements, and the absence of significant combustible
loads and ignition sources in the fire areas associated with this
exemption, the NRC staff has concluded that application of 10 CFR part
50, Appendix R, Section III.G.2 for these fire areas is not necessary
to achieve the underlying purpose of this regulation.
The NRC staff has determined that the exemption to allow PBAPS the
use of operator manual actions in lieu of the requirements specified in
10 CFR part 50, Appendix R, Section III.G.2 does not increase the
probability or consequences of previously evaluated accidents. This
determination is based on the NRC staff finding that the operator
manual actions are not the sole form of protection relied upon due to
the other fire protection features in place and the manual actions are
considered feasible and provide safe shutdown capability following a
fire. The combination of the operator manual actions, in conjunction
with all of the measures and systems discussed above, results in an
adequate level of protection. No new accident initiators are created by
allowing use of operator manual actions in the fire areas identified in
the exemption and the probability of postulated accidents is not
increased. Similarly, the consequences of postulated accidents are not
increased. Therefore, there is no undue risk (since risk is probability
multiplied by consequences) to public health and safety.
3.7 Consistent With Common Defense and Security
The proposed exemption would allow PBAPS the use of specific
operator manual actions in lieu of meeting the requirements specified
in 10 CFR part 50, Appendix R, Section III.G.2. This change, to the
operation of the plant, has no relation to security issues nor does it
diminish the level of safety from what was intended by the requirements
contained in Section III.G.2. Therefore, the common defense and
security is not impacted by this exemption.
3.8 Special Circumstances
One of the special circumstances described in 10 CFR
50.12(a)(2)(ii) is that the application of the regulation is not
necessary to achieve the underlying purpose of the rule. The underlying
purpose of 10 CFR Part 50, Appendix R, Section III.G.2 is to ensure
that one of the redundant trains necessary to achieve and maintain hot
shutdown conditions remains free of fire damage in the event of a fire.
For the fire areas specified in Table 1 of this exemption, the NRC
staff finds that the operator manual actions are feasible and can be
reliably performed and the existing configuration described herein will
ensure that a redundant train necessary to achieve and maintain safe
shutdown of the plant will remain free of fire damage in the event of a
fire in these fire zones. Since the underlying purpose of 10 CFR part
50, Appendix R, Section III.G is achieved, the special circumstances
required by 10 CFR 50.12(a)(2)(ii) for the granting of an exemption
from 10 CFR part 50, Appendix R, Section III.G.2 exist.
4.0 Conclusion
Accordingly, the Commission has determined that, pursuant to 10 CFR
50.12(a), the exemption is authorized by law, will not present an undue
risk to the public health and safety, and is consistent with the common
defense and security. Also, special circumstances are present such that
application of the regulation in these particular circumstances is not
necessary to achieve the underlying purpose of the rule. Therefore, the
Commission hereby grants Exelon an exemption from the requirements of
Section III.G.2 of Appendix R of 10 CFR Part 50, to PBAPS Units 2 and 3
for the 25 operator manual actions specified in Table 1.
Pursuant to 10 CFR 51.32, the Commission has determined that the
granting of this exemption will not have a significant effect on the
quality of the human environment (74 FR 5191).
This exemption is effective upon issuance.
Dated at Rockville, Maryland, this 30th day of January 2009.
For the Nuclear Regulatory Commission
Joseph G. Giitter,
Director, Division of Operating Reactor Licensing, Office of Nuclear
Reactor Regulation.
[[Page 6426]]
Table 1--Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Actions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fire affected
Operator manual Table A-4 cross Purpose component Initiating fire Actions Action locations Notes
action number reference information area (FA)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1................ 2AP35............ Defeat 2A residual External wiring 2, 57........... Install U3 plug-in Cable Spreading Note 1
heat removal (RHR) (located in the test switch 3-10A- Room, Rm 302, FA Note 2
pump (2AP35) trip initiating fire J1B at Panel 30C33. 25.
signal generated areas) to the Unit
by fire damage to 3 RHR logic in
Unit 3 RHR Logic. panel 30C33
(located in Room
(Rm) 302, FA 25).
2................ 2BS456........... Transfer 125 VDC Loss of power (due 2, 4, 6S, 57.... 1. Verify Breaker 1. E-23 Bus Room, Note 1
Battery Charger to fire damage in 52-6011 at E234-T- Rm 263, FA 35. Note 4
2BD003 from normal initiating fire B is closed prior
source (E224-T-B) areas) to 125 VDC to operating
to its alternate Battery Charger switch 2BS456.
source (E234-T-B) 2BD003 (located in
due to fire damage. Rm 226, FA 36).
2. Operate switch 2. E-42 Bus Room, ............
2BS456 to restore Rm 226, FA 36.
power for Battery
Charger 2BD003
from an alternate
power source.
3................ 2DS456........... Transfer 125 VDC Loss of power (due 2, 6S, 38, 57... 1. Verify Breaker 1. E-23 Bus Room, Note 1
Battery Charger to fire damage in 52-6022 at E234-T- Rm 263, FA 35. Note 4
2DD003 from normal initiating fire B is closed prior Note 5
source (E424-W-A) areas) to 125 VDC to operating
to its alternate Battery Charger switch 2DS456.
source (E234-T-B) 2DD003 (located in
due to fire damage. Rm 226, FA 36).
2. Operate switch 2. E-42 Bus Room,
2DS456 to restore Rm 226, FA 36.
power for Battery
Charger 2DD003
from an alternate
power source.
4................ 3BP35............ Defeat 3B RHR pump External wiring 2, 57........... Install U2 plug-in Cable Spreading Note 1
(3BP35) trip (located in test switch into Room, Rm 302, FA Note 2
signal generated initiating fire test jack 2-10A- 25.
by fire damage to areas) to the Unit J1A at panel 20C32.
Unit 2 RHR logic. 2 RHR logic in
panel 20C32
(located in Rm
302, FA 25).
5................ 30S546........... Transfer instrument Loss of power (due 13N............. Operate key switch Cable Spreading
power supplies to fire in 30S546 to restore Room, Rm 302, FA
from normal source initiating fire power to 25.
(panel 30Y050) to area) to instrument panel
alternate power instrument power from 20Y033.
source (panel supply panel
20Y033) due to 30Y050 (located in
fire damage. Rm 302, FA 25).
6................ 3AS456........... Transfer 125 VDC Loss of power (due 13N............. 1. Verify Breaker 1. E-12 Bus Room, Note 4
Battery Charger to fire damage in 52-5934 at E124-T- Rm 227, FA 39.
3AD003 from its initiating fire B is closed prior
normal power area) to 125 VDC to operating
source (E134-T-B) Battery Charger switch 3AS456.
to its alternate 3AD003 (located in
power source (E124- Rm 261, FA 32).
T-B) due to fire
damage.
2. Operate switch 2. E-33 Bus Room,
3AS456 to restore Rm 261, FA 32.
power for Battery
Charger 3AD003
from an alternate
power source.
[[Page 6427]]
7................ 3CS456........... Transfer 125 VDC Loss of power (due 13N, 13S, 26, 1. Verify Breaker 1. E-12 Bus Room, Note 1
Battery Charger to fire damage in 57, 58. 52-5911 at E124-T- Rm 227, FA 39. Note 3
3CD003 from its initiating fire B is closed prior Note 4
normal power areas) to 125 VDC to operating Note 6
source (E334-R-B) Battery Charger switch 3CS456.
to its alternate 3CD003 (located in
power source (E124- Rm 261, FA 32).
T-B) due to fire
damage.
2. Operate switch 2. E-33 Bus Room,
3CS456 to restore Rm 261, FA 32.
power for Battery
Charger 3CD003
from an alternate
power source.
8................ MO3-10-89A....... Manually operate MO- Loss of power (due 13N............. 1. Open breaker 52- 1. U3 RBCCW Room,
3-10-089A if to fire damage in 3623 at E134-W-A. Rm 162, FA 2.
electrical the initiating
operating fire area) to MO-3-
capability is lost 10-089A, 3A RHR
due to fire damage. Heat Exchanger
High Pressure
Service Water Heat
Outlet (located in
Rm 156, FA 2).
2. Manually open MO- 2. U3 RHR Pump
3-10-089A. Room, Rm 156, FA 2.
9................ MO-2486.......... Manually operate Loss of power (due 50, 54.......... 1. Open breaker 52- 1. E2 Diesel Note 7
valve MO-2486 upon to fire damage in 5442 at E234-D-A. Generator Room, Rm
loss of electrical the initiating 817, FA 45.
operating fire areas) to MO-
capability due to 2486, High
fire damage. Pressure Service
Water Normal
Discharge Valve
(located in Rm
815, FA 54).
2. Manually open MO- 2. Cardox Room, Rm
2486. 815, FA 54.
10............... MO-2486.......... Locally operate MO- Loss of power (due 4, 38, 57....... 1. Open breaker 52- 1 and 2. E2 Diesel Note 1
2486 from the MCC to fire damage in 5442 at E234-D-A. Generator Room, Rm
if the fire has the initiating 817, FA 45.
caused loss of fire areas) to MO-
remote operating 2486, High
capability. Pressure Service
Water Normal
Discharge Valve
(located in Rm
815, FA 54).
2. Open valve using
contactor at MCC.
11............... MO-3486.......... Manually operate Loss of power (due 50, 54.......... 1. Open breaker 52- 1. E2 Diesel Note 7
valve MO-3486 upon to fire damage in 5441 at E234-D-A. Generator Room, Rm
loss of electrical the initiating 817, FA 45.
operating fire areas) to MO-
capability due to 3486, High
fire damage. Pressure Service
Water Normal
Discharge Valve
(located in Rm
815, FA 54).
2. Manually open MO- 2. Cardox Room, Rm
3486. 815, FA 54.
[[Page 6428]]
12............... MO-3486.......... Locally operate MO- Loss of power (due 57, 58.......... 1. Open breaker 52- 1 and 2. E2 Diesel Note 1
3486 from the to fire damage in 5441 at E234-D-A. Generator Room, Rm Note 3
motor control the initiating 817, FA 45.
center (MCC) if fire areas) to MO-
the fire has 3486, High
caused loss of Pressure Service
remote operating Water Normal
capability. Discharge Valve
(located in Rm
815, FA 54).
2. Open valve using
contactor at MCC.
13............... MO2-10-034A...... Manually open valve Loss of power (due 4, 57........... 1. Open breaker 52- 1. U2 Reactor Bldg, Note 1
MO-2-10-034A if to fire damage in 3832 at E324-R-B. Rm 212, FA 6S.
electrical the initiating
operating fire areas) to MO-
capability is lost 2-10-34A, RHR Loop
due to fire damage. A Full Flow Test
Valve (located in
Rm 1, FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-034A. Rm 1, FA 5.
14............... MO2-10-039A...... Manually open valve Loss of power (due 4, 57........... 1. Open breaker 52- 1. U2 Reactor Bldg, Note 1
MO-2-10-039A if to fire damage in 3831 at E324-R-B. Rm 212, FA 6S.
electrical the initiating
operating fire areas) to MO-
capability is lost 2-10-039A, RHR
due to fire damage. Loop A Torus
Header Valve
(located in Rm 1,
FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-039A. Rm 1, FA 5.
15............... MO3-10-034A...... Manually open valve Loss of power (due 13N, 26......... 1. Open breaker 52- 1. U3 Reactor Bldg,
MO-3-10-034A if to fire damage in 3832 at E334-R-B. Rm 257, FA 13S.
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-34A, RHR Loop
due to fire damage. A Full Flow Test
Valve (located in
Rm 37, FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-034A. Rm 37, FA 12.
16............... MO3-10-039A...... Manually open valve Loss of power (due 13N, 26......... 1. Open breaker 52- 1. U3 Reactor Bldg,
MO-3-10-039A if to fire damage in 3831 at E334-R-B. Rm 257, FA 13S.
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-039A, RHR
due to fire damage. Loop A Torus
Header Valve
(located in Rm 37,
FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-039A. Rm 37, FA 12.
17............... MO2-10-034B...... Manually open valve Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 RBCCW Room,
MO-2-10-034B if to fire damage in 3933 at E424-W-A. Rm 105, FA 2.
electrical the initiating
operating fire area) to MO-2-
capability is lost 10-034B, RHR Loop
due to fire damage. B Full Flow Test
Valve (located in
Rm 1, FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-34B. Rm 1, FA 5.
[[Page 6429]]
18............... MO2-10-039B...... Manually open valve Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 RBCCW Room,
MO-2-10-039B if to fire damage in 3942 at E424-W-A. Rm 105, FA 2.
electrical the initiating
operating fire area) to MO-2-
capability is lost 10-039B, RHR Loop
due to fire damage. B Torus Header
Valve, (located in
Rm 1, FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-39B. Rm 1, FA 5.
19............... MO2-10-89D....... Manually open valve Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 RBCCW Room,
MO-2-10-089D if to fire damage in 3931 at E424-W-A. Rm 105, FA 2.
electrical the initiating
operating fire area) to MO-2-
capability is lost 10-089D, 2D RHR
due to fire damage. Heat Exchanger
High Pressure
Service Water
Outlet Valve
(located in Rm
104, FA 2).
2. Manually open MO- 2. U2 RHR Pump
2-10-89D. Room, Rm 104, FA 2.
20............... MO3-10-034B...... Manually open valve Loss of power (due 2, 57, 58....... 1. Open breaker 52- 1. U3 Reactor Bldg, Note 1
MO-3-10-034B if to fire damage in 3933 at E434-R-B. Rm 250, FA 13N. Note 3
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-034B, RHR
due to fire damage. Loop B Full Flow
Test Valve
(located in Rm 37,
FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-34B. Rm 37, FA 12.
21............... MO3-10-039B...... Manually open valve Loss of power (due 2, 57, 58....... 1. Open breaker 52- 1. U3 Reactor Bldg, Note 1
MO-3-10-039B if to fire damage in 3942 at E434-R-B. Rm 250, FA 13N. Note 3
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-039B, RHR
due to fire damage. Loop B Torus
Header Valve
(located in Rm 37,
FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-39B. Rm 37, FA 12.
22............... MO3-10-89D....... Manually operate MO- Loss of power (due 58.............. 1. Open breaker 52- 1. U3 Reactor Bldg, Note 3
3-10-089D if to fire damage in 3931 at E434-R-B. Rm 250, FA 13N.
electrical the initiating
operating fire area) to MO-3-
capability is lost 10-089D, 3D RHR
due to fire damage. Heat Exchanger
High Pressure
Service Water
Outlet Valve
(located in Rm
159, FA 10).
2. Manually open MO- 2. U3 RHR Pump
3-10-089D. Room, Rm 159, FA
10.
23............... MO2-10-25B....... Manually operate MO- Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 Reactor Bldg,
2-10-025B if to fire damage in 25B02 at N210025B, Rm 205, FA 6N.
electrical the initiating LPCI Swing Bus B.
operating fire area) to MO-2-
capability is lost 10-025B, RHR Loop
due to fire damage. B Inboard
Discharge Valve
(located in Rm
204, FA 6N).
2. Manually open MO- 2. U2 Reactor Bldg,
2-10-025B. Rm 204, FA 6N.
[[Page 6430]]
24............... MO3-10-25A....... Manually operate MO- Loss of power (due 13N............. 1. Open breaker 52- 1. U3 Reactor Bldg,
3-10-025A if to fire damage in 25A02 at N310025A, Rm 257, FA 13S.
electrical the initiating LPCI Swing Bus A.
operating fire area) to MO-3-
capability is lost 10-25A RHR Loop A
due to fire damage. Inboard Discharge
Valve (located in
Rm 248, FA 13S).
2. Manually open 2. U3 Reactor Bldg,
valve MO-3-10-025A. Rm 248, FA 13S.
25............... MO3-10-25B....... Manually operate MO- Loss of power (due 13S............. 1. Open breaker 52- 1 and 2. U3 Reactor
3-10-025B if to fire damage in 25B02 at N310025B Bldg, Rm 250, FA
electrical the initiating LPCI Swing Bus B. 13N.
operating fire area) to MO-3-
capability is lost 10-025B, RHR Loop
due to fire damage. B Inboard
Discharge Valve
(located in Rm
249, FA 13N).
2. Open MO-3-10-
025B from MCC
Contactor.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table Notes:
Note 1: Fire Area 57 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.
Note 2: This action has been slightly modified from that described in the original submittal to make the action simpler to perform, but the action
location, timing and outcome are the same. The original action was to reach inside the logic cabinet and physically manipulate a relay. A plug-in
switch was fabricated so the operator would not have to handle an energized relay. The outcome is the same (the relay is actuated).
Note 3: Fire Area 58 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.
Note 4: When the station procedures were developed, an initial step of verification of the breaker position (closed) of the alternate power source was
added. Appendix R permits the assumption that equipment that is not fire affected will be in its expected position. So verification of this breaker
position is not required for Appendix R compliance. Operations determined that they wanted to add a step to verify the position of the breaker as a
precaution. This extra step was added to this Table since the action is performed in a different fire area than the steps associated with operating
the switch. It is important to show that all actions taken by the operators are not in the same fire area where the fire is postulated.
Note 5: Fire Area 2 was omitted from the table in Revision 4. Fire Area 2 is listed in the revision 0, 1 and 2 tables. Fire Area 2 (which subsequently
was split into Fire Area 2, 57 and 58) fire guide has always contained the attachment to transfer 125 VDC battery charger 2DD003 from the normal to
the backup source.
Note 6: Fire Area 4 no longer credits use of this manual action.
Note 7: The action to manually open MO-2486 and MO-3486 (physically open the valve at the valve itself) is performed in the same fire area as the
initiating fire area. There is 150 minutes (2.5 hours) between the start of the event and when the valve is to be opened. A fire in the Cardox Room
will be extinguished and the smoke vented from the area long before the action needs to be performed. The operators will not have any delay or need
Self Contained Breathing Apparatus to perform this action.
General Note: Table A-4 Revision 4 was a summary of information that was in the Peach Bottom Cable/Raceway analysis. This program deleted a ``zero''
that padded many component numbers, and some hyphens. The component number provided in the above table uses the correct nomenclature that is also used
in the post-fire shutdown fire guides, safe shutdown calculations and plant labels.
[FR Doc. E9-2615 Filed 2-6-09; 8:45 am]
BILLING CODE 7590-01-P